Search
Three years after Russia’s full-scale invasion and war of aggression against Ukraine, the EU has adopted the 16th package of sanctions against Russia.
A 16th package of sanctions against Russia was formally adopted by the European Council on 24 February 2025. This date also marks the third year of Russia’s full-scale invasion of Ukraine. The package is comprehensive and targets key sectors of the Russian economy, including energy, trade, transport, infrastructure, and banking. The measures are set out in several regulations and decisions accessible in the Official Journal of the European Union, which can be found here.
Below, we have summarised some of the most significant changes.
In addition to the existing ban on EU imports of processed aluminium goods from Russia, the new sanctions introduce a ban on imports of primary aluminium, which generates significant revenues for Russia. The new ban on primary aluminium will be phased in to facilitate a smooth transition for businesses. During the phase-in period, up to 275,000 tons of imports of primary aluminium from Russia will be allowed over the next 12-month period before the ban takes full effect on 26 February 2026. After the ban is in full effect, contracts for primary aluminium signed before February 2025 will be granted an exemption for up to 50,000 tons until the end of 2026.
New export restrictions have been imposed on industrial goods, specifically targeting minerals, chemicals, steel, glass materials, and fireworks that have military significance.
Additionally, the dual-use export restrictions have been expanded to include more items in order to restrict Russia’s access to key technologies used on the battlefield. The new items covered are: (i) chemical precursors for making chloropicrin and other riot control agents used by Russia as chemical weapons, (ii) software for CNC machine tools used to produce weapons and video game controllers used by the Russian military to operate unmanned aerial vehicles (UAVs), and (iii) chromium ores and compounds due to their military application.
Further, the limited derogations and exemptions for dual-use and advanced technology exports have been clarified and further tightened to ensure effective enforcement by customs and licensing authorities. Such exports are only allowed for humanitarian or natural disaster purposes or related to health concerns. Also, medical or pharmaceutical products are exempt if not listed as a ‘common high priority items’.
The provision of temporary storage or the placement under free zones procedures of Russian crude oil or petroleum products in EU ports is now completely banned. Consequently, the previous exemption allowing oil when it complied with the price cap and went to a third country, is no longer applicable.
The prohibition to provide goods, technology, and services for the completion of liquefying natural gas (LNG) projects in Russia has been extended to include crude oil projects in Russia. Additionally, the already existing software ban is also extended to restrict the export, supply, or provision of software related to oil and gas exploration to Russia.
The flight ban has been expanded to enable the inclusion of third-country carriers that operate domestic flights within Russia or supply aviation goods to Russian airlines or for domestic flights in Russia. If an airline is listed, it will be prohibited from flying to the EU.
An amendment has been made to the road transport prohibition to prevent Russian ownership from exceeding 25% in EU road transport companies. This measure aims to close potential loopholes that could be used to circumvent the sanctions.
The EU has implemented a full transaction ban targeting certain listed ports, locks and airports in Russia that are used for the transfer of UAVs, missiles and related technology and components to Russia, or to circumvent the oil price cap or other restrictive measures by vessels. The transaction ban covers two Moscow airports, four regional airports, and certain listed ports and locks.
The new sanctions also include a ban on construction services provided by EU operators in Russia related to infrastructure projects, including civil engineering works. Architectural and engineering services are already part of the EU’s restrictive measures.
The new sanctions impose a transaction ban on credit or financial institutions established outside Russia that use the ‘System for Transfer of Financial Messages’ (SPFS), which is a specialised financial messaging service developed by the Central Bank of Russia to neutralise the effect of the EU restrictive measures.
Further, the new sanctions extend the restrictive measures regarding the provision of specialised financial messaging services to include 13 regional banks in Russia, which are considered important for the Russian financial and banking systems.
The EU has suspended the broadcasting activities of eight more media outlets operating within the EU or targeting EU audiences. These media outlets have been suspended because they are under the direct control of Russian authorities and consistently spread misinformation and propaganda, posing a threat to the public order and security in the EU.
To further target the Russian shadow fleet and vessels contributing to Russia’s energy sector, the EU has added 74 more vessels to the list of those banned from accessing EU ports and locks and from receiving certain maritime transport services. This addition increases the total number of restricted vessels to 153.
The new sanctions expand the list of entities directly supporting Russia’s military and industrial complex in its war of aggression against Ukraine by adding 53 new entities. These entities, which are subject to stricter export restrictions, are based in Russia as well as in third countries, including China (and Hong Kong), India, Kazakhstan, Singapore, Türkiye, the United Arab Emirates, and Uzbekistan. These new entities have been identified as being involved in the circumvention of existing EU sanctions.
The EU has also introduced two new criteria for adding individuals and entities to asset freeze lists. The first criterion targets those who facilitate the operations of unsafe oil tankers, while the second focuses on individuals and entities involved in, supporting, or benefiting from the Russian military and industrial complex. In addition to these new criteria, the new sanctions package includes 83 additional listings, including 48 individuals and 35 entities.
Furthermore, the new sanctions extend the due diligence requirements for EU operators exporting two particular items found in Iranian and Chinese drones used by Russia. The two items are listed in Annex XLVIII to Regulation (EU) No 833/2014. These due diligence requirements apply to exports of the items to third countries, except for the partner countries of the EU. The EU operators covered must implement due diligence mechanisms capable of identifying, assessing, and mitigating the risks of re-exportation to Russia, including ensuring that their foreign subsidiaries do the same.
To prevent Russia from evading EU sanctions through the territory of Belarus, some of the new measures against Russia have been mirrored in the Belarus sanctions regime. These measures include, for example, the export restrictions on dual-use and advanced technology goods, the road transport prohibition to prevent ownership from exceeding 25% in EU road transport companies, and one of the new listing criteria, which allows the EU to impose targeted measures against individuals or entities that are part of, support, or benefit from the military and industrial complex of Belarus.
As part of the new sanctions package, the EU has also strengthened its sanctions concerning Crimea and Sevastopol, and the non-government-controlled areas of Donetsk, Kherson, Luhansk, and Zaporizhzhia. The restrictions concern the provision of services such as accounting, consulting, engineering and legal advisory services, as well as the provision of certain software and intellectual property. The sanctions regime for these non-government-controlled areas of Ukraine will remain in place until February 2026.
For more information on the previous EU sanctions packages, please see Gorrissen Federspiel’s newsletters of 19 December 2024, 25 June 2024, 27 February 2024, 19 December 2023, 26 June 2023, 27 February 2023, 19 December 2022, 7 October 2022, 8 June 2022, 11 April 2022, 16 March 2022, 10 March 2022, 2 March 2022, 28 February 2022, and 24 February 2022.